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NOTE OF ISSUE:WITHOUT JURY

Document Morton Village Realty Co., Inc. v. Plainview Hardware Inc. et al, 616328/2018, 109 (N.Y. Sup. Ct., Nassau County Oct. 22, 2019)

[ ] Tort[ ] Motor vehicle ] Medical ] Other [ [ negligence malpractice tort [ X ] Contract ] Contested [ } Uncontested [ Tax certiorari [ Condemnation [ Other (not [ matrimonial matrimonial itemized above) specify Special preference under claimed on the ground that for Plaintiff(s) Attorney(s) & P.O.

Clerk will note of unless by a certifkate not accept this issue acc:n;::!sd readiñêss.

Medical reports exchanged Appraisal reports exchanged Compliance with the Rules in matrimonial actions Discovery proceedings to be completed pursuant There are no nutstanding requests for discovery.

If a medical nialpractice action, there has been conipliance with any order issued pursuañt to 22 NYCRR 202.56.

Address Office -- type name Signature David Gise, Esq. below.

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- Sharon Gianelli
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- Rivkin Radler

ANSWER

Document Morton Village Realty Co., Inc. v. Plainview Hardware Inc. et al, 616328/2018, 13 (N.Y. Sup. Ct., Nassau County Feb. 4, 2019)

Pro Se, separating herself from all other Defendants hereby answers the Plaintiff's complaint as follows: Defendant generally denies each and every allegation contained in the Complaint and each cause of action set down therein and denies that Plaintiff sustained damages in any and all such sums sums alleged or in any other at all.

For a Fourth and Separate Affirmative Defense to the Complaint on file herein, and to and cause of action set down this Defendant Plaintiff each every therein, answering alleges that engaged in conduct and activities by reason of which Plaintiff is equitably estopped to assert any alleged claims or demands against this answering Defendant.

For a Fifth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant alleges that Plaintiff engaged in conduct and activities tainted with bad faith by reason of which Plaintiff should not permitted to use processes of for further of bad be the this court instances faith.

For a Ninth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering defendant alleges that if Plaintiff suffered any loss, damage or injury and this is expressly denied, such damage was the direct and of omissions of or of this proximate result the acts or others and not the acts omissions answering Defendant.

For and Tenth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant reserves her right to amend this Answer to add other applicable and pertinent Affirmative any Defense not otherwise listed.

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- Sharon Gianelli
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- Plainview Hardware
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- Rivkin Radler

ANSWER

Document Morton Village Realty Co., Inc. v. Plainview Hardware Inc. et al, 616328/2018, 11 (N.Y. Sup. Ct., Nassau County Feb. 1, 2019)

Pro Se, separating himself from all other Defendants hereby answers the Plaintiff's complaint as follows: Defendant generally denies each and every allegation contained in the Complaint and each cause of action set down therein and denies that Plaintiff sustained damages in any and all sums alleged or in any other such sums at all.

For a Fourth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant alleges that Plaintiff engaged in conduct and activities by reason of which Plaintiff is equitably estopped to assert any claims or demands against this Defendant.

For a Fifth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant alleges that Plaintiff engaged in conduct and activities tainted with bad faith by reason of which Plaintiff should not be permitted to use the processes of this court for further instances of bad faith.

For a Ninth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering defendant alleges that if Plaintiff suffered any loss, damage or injury and this is expressly denied, such damage was the direct and result of or omissions not the acts or omissions of this proximate Defendant.

For and Tenth and Separate Affirmative Defense to the Complaint on file herein, and to each and every cause of action set down therein, this answering Defendant reserves her right to amend this Answer to add any other applicable and pertinent Affirmative Defense not otherwise listed.

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